Privacy Policy

A. Through Technology:

• We automatically collect data such as your email address (used initially to activate our Services), browser type, IP address, device identifiers, and usage data.
• Cookies and similar tracking technologies are used to store information related to your interaction with our Site.

B. Through Registration:

• To access our Services, you must register and provide details such as your full name, email, phone number, mailing address, and professional information (e.g., company affiliation, job title, and NMLS number where applicable).
• When you apply for a loan or mortgage through our Services, any submitted Loan Information is collected as part of your Personal Information.

C. Through Your Use of the Service (Customer Content):

• As you use the Service, we collect the Customer Content you create, upload, or receive, including records about your leads, borrowers, and business partners; notes and tasks; documents you attach; and communications sent and received through your Leaf360 business phone number and connected email accounts.
• Customer Content may include Personal Information about your clients. You are responsible for having the necessary rights and consents to enter that information into the Service.

Our Apps collect the information described in Section 3 and may additionally access the following, each only with your permission through the operating system’s permission prompts, and only for the purpose stated:

• Device identifiers and push notification tokens: used to deliver notifications (including incoming call alerts) to your device and to keep your session secure. A trusted-device record is kept for up to 30 days to support biometric sign-in.
• Face ID / Touch ID: used to sign you in. Biometric authentication is performed entirely on your device by Apple; your biometric data is never transmitted to us and we never receive it.
• Camera and Photo Library: used only when you choose to attach a photo to a text message or a chat with LIA, or to scan a document.
• Microphone: used only when you record a voice message, place or answer a call through your Leaf360 business line, or dictate a message.
• Speech Recognition: when you dictate a message, audio may be processed by Apple’s speech recognition service in accordance with Apple’s privacy policy. We receive only the resulting text.
• Contacts: accessed only if you choose to import contacts from your device into Leaf360. We do not scan or upload your address book without that action. The App may also provide caller-ID information for numbers already stored in your Leaf360 account; this reads your Leaf360 records, not your device’s address book.
• Location (while using the App): used only for location-based features such as home search. We do not track your location in the background.

We do not sell any information collected through the Apps.

A. Use of Personal Information:

• We use your Personal Information to communicate with you, deliver and enhance our Services, verify your identity and professional credentials, process transactions, provide customer support, and maintain the security of our Services.
• We do not share your Personal Information with third parties for marketing purposes without your explicit consent.

B. Use of Loan Information:

Any Loan Information you provide is considered part of your Personal Information and is used exclusively to facilitate the loan or mortgage application process.

C. Use of Customer Content:

Customer Content is used only to provide the Service to you and your organization, including displaying your records, sending and receiving your communications, generating the AI features described in Section 7 when you use them, and producing reports and insights for your organization.

D. Sharing with Service Providers and CRM Integration:

Your information, including Loan Information and Customer Content, is shared only with the trusted service providers described in Sections 7 and 9 and, if applicable, the integrated Customer Relationship Management (CRM), loan origination, or lender system of your choice. Such sharing is governed by strict contractual and technical safeguards.

Important: We will never re-sell your Personal Information, Loan Information, or Customer Content under any circumstances.

E. Use of Non-Personal Information:

Non-Personal Information is used for analytics, improving our Services, and may be shared with partners for aggregated reporting.

The Service includes AI-powered features, including the LIA assistant (chat, briefs, drafting, and suggested actions), call transcription and call insights (summaries, action items, and coaching), and certain document and voice features. These features are powered by third-party AI Providers that process data on our behalf.

A. What data is sent. When you use an AI feature, we transmit the information needed to produce the result. Depending on the feature, this may include:

• the messages, questions, and instructions you submit to LIA;
• the Customer Content needed to respond, such as lead, loan, and partner names and contact details, notes, tasks, pipeline and loan status details, and communication history;
• call recordings (for transcription) and call transcripts (for insights and coaching);
• documents you attach to a chat; and
• your name, role, and writing-style preferences, so responses are personalized to you.

Sensitive borrower identifiers are excluded. Social Security numbers, dates of birth, and similar sensitive identifiers are removed from the information sent to AI Providers, and SSN-formatted text appearing in notes or transcripts is masked before transmission.

B. Who receives it. Data is transmitted through Leaf 360’s servers to the following AI Providers:

• Anthropic, PBC (Claude): powers the LIA assistant and generates call insights, summaries, and drafts.
• Deepgram, Inc.: transcribes call recordings and voice messages.
• OpenAI, L.L.C.: used for certain document-processing and voice-agent features.

C. How it is used. AI Providers process this data solely to generate the requested result for you. Under our agreements with them, AI Providers do not use your data to train or improve their models, do not sell it, and are required to protect it with security and confidentiality measures equivalent to our own. AI Providers may retain data for a limited period for abuse monitoring and legal compliance as described in their own policies, after which it is deleted.

D. Your permission. Before an AI feature first sends your data, the Apps present a disclosure describing what is shared, who receives it, and how it is used, and ask for your permission. You may decline and continue to use the rest of the Service; AI features will remain unavailable until you agree. You may withdraw your permission at any time by contacting us at lia@leaf360.io, after which AI features will be disabled for your account.

E. Automated decisions. AI features provide information, drafts, and suggestions to assist you. They do not make lending, credit, or eligibility decisions about any borrower.

We share information with service providers who process it on our behalf under contracts that restrict their use of the data to providing services to us and require appropriate security measures. These include:

• Anthropic, Deepgram, and OpenAI: AI Providers (see Section 7).
• Twilio Inc.: voice calling, text messaging, and call recording.
• Amazon Web Services, Inc.: encrypted file storage for documents, media, and recordings.
• MongoDB, Inc. (MongoDB Atlas): encrypted database hosting.
• Apple Inc. and Google LLC: push notification delivery and, on Apple devices, on-device speech recognition for dictation.
• Google LLC and Microsoft Corporation: connected email accounts, only when you connect them.
• Integration platforms and connected tools: third-party tools you choose to connect to your account, only with your authorization.
• Loan origination systems and lenders: only when you choose to submit or synchronize a loan file.

We employ industry-standard security measures to protect your data, including:

• Encryption: Data is encrypted in transit using TLS and stored in encrypted storage at rest.
• Firewall & Access Controls: Robust network protections and strict internal policies ensure only authorized personnel can access your information, and access is limited to what each role requires.
• Per-user access controls: Within an organization, users see only the records and communications they are authorized to see.
• Secure authentication: Mobile sign-in supports device biometrics and trusted-device verification.
• Regular Audits: Routine reviews and system updates are conducted to address potential vulnerabilities.

No method of transmission or storage is completely secure; if we become aware of a security incident affecting your Personal Information, we will notify you as required by applicable law.

Any Loan Information you save on Leaf 360 is treated as highly sensitive Personal Information. In addition to our standard security protocols, we apply enhanced measures to protect your Loan Information:

• Encryption: Loan data is encrypted in transit and stored in encrypted storage at rest.
• Sensitive identifiers: Social Security numbers are masked in the user interface and, together with dates of birth, are excluded from information sent to AI Providers (Section 7).
• Dedicated Security Measures: We use robust firewalls, strict access controls, and regular security audits to prevent unauthorized access.
• CRM and Lender Integration Safeguards: Loan Information is shared only with the integrated CRM, loan origination system, or lender of your choice and solely to facilitate your workflow. Such integrations are subject to binding contractual obligations ensuring the recipient upholds security and confidentiality standards equivalent to ours.
• Commitment: Your Loan Information is never shared with third parties beyond the approved integrations and service providers described in this Policy and is never re-sold.

You have the right to opt out of marketing communications at any time by using the unsubscribe link in our emails or by adjusting your settings on our Site. Note that you will still receive essential administrative communications.

Depending on where you live, you may also have the right to request access to, correction of, deletion of, or a portable copy of your Personal Information, to withdraw consent to AI features (Section 7(D)), and to opt out of certain uses of your information. We do not sell Personal Information and do not share it for cross-context behavioral advertising. To exercise any of these rights, contact us using the details in Section 16. We will not discriminate against you for exercising your rights.

If you are a client of a Leaf360 user (for example, a borrower whose information was entered by a loan officer), please direct requests to that organization first; we will assist them in responding.